Corporate Restructuring-Application for Private Corporations
Discover a practical approach and guidance on identifying, planning, documenting, and implementing reorganizations of private corporate groups.
Those involved with reorganizing private corporations need to consider a wide range of technical rules, develop a plan that meets the client’s objectives, navigate the practical challenges of implementing the plan, and communicate the plan to other professionals. This seminar provides a practical approach and guidance on identifying, planning, documenting, and implementing reorganizations of private corporate groups. Participants will apply this approach using mini cases throughout the seminar. A brief high-level review of Income Tax Act (ITA) sections and other common technical rules will be provided, but participants should have a good working knowledge of these rules.
WHO WILL BENEFIT:
Although most tax professionals would benefit from this seminar, it particularly targets practitioners and managers involved in reorganizations or tax planning for groups of privately held companies.
By the end of this course, participants should be able to:
- identify problems with corporate structures and develop alternatives,
- identify and analyze income tax rules that can impact the proposed transactions, and
- prepare a structured plan to implement a reorganization.
- The collection and evaluation of client information and objectives
- The identification of alternatives and development of a plan
- A high-level review of key technical Income Tax Act provisions, including Section 85, QSBC rules, Section 55, Part IV tax, Stop-loss rules, and Attribution rules and TOSI
- Loss utilization and employee buy-in
- An understanding of the basic Income Tax Act sections that are commonly used in reorganizations, including Sections 85 and 86, as well as related and associated corporation rules.
- Prior attendance in the seminars Corporate Restructuring – Fundamentals and Corporate Tax – Small Business Deduction & Private Corporate Groups is recommended.
COURSE LEADER: PETER MOREIRA, CPA, CGA